- 7 - deductions claimed. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). 1. Respondent's Reconstruction of Petitioner's Income Pursuant to a reconstruction of petitioner's income for the taxable year 1994, respondent determined that petitioner had failed to report gross income in the amount of $4,578. Taxpayers are required to maintain adequate records of taxable income. Sec. 6001. Where a taxpayer fails to produce or maintain adequate records from which actual income may be ascertained, the Commissioner may reconstruct a taxpayer's income by any method that clearly reflects income. Sec. 446(b); Goodmon v. Commissioner, 761 F.2d 1522, 1524 (11th Cir. 1985); Petzoldt v. Commissioner, 92 T.C. 661, 687, 693 (1989). The method of reconstructing income need only be reasonable in light of all surrounding circumstances. Petzoldt v. Commissioner, supra at 687. The source and application of funds method has been regarded as a reasonable method of determining income. United States v. Johnson, 319 U.S. 503, 517-518 (1943); Meier v. Commissioner, 91 T.C. 273, 295-296 (1988). As explained by this Court in DeVenney v. Commissioner, 85 T.C. 927, 930 (1985): The * * * [source and application of funds] method is based upon the assumption that the amount by which a taxpayer's cash expenditures during a taxable period exceed * * * [the taxpayer's] known sources of income for that period is taxable income, unless the taxpayerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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